For years, pharmacy benefits have been one of the least transparent parts of employer healthcare spending.
Most self-funded employers know their pharmacy trend is rising. Many know specialty drugs are a major part of the problem. But far fewer can confidently answer basic questions like: What are we actually paying net of rebates? Which drugs are driving the increase? Where are incentives misaligned? And which parts of the system are helping reduce cost versus simply moving it around?
That’s changing.
In early 2026, a series of federal actions pushed pharmacy benefit transparency much closer to the center of the employer conversation. PBM reform legislation passed in February. Around the same time, the Department of Labor proposed stronger fee-disclosure requirements for PBMs serving self-insured plans. The message is clear: plan sponsors are increasingly expected to understand how pharmacy dollars flow, where conflicts may exist, and whether their current arrangements are truly serving the plan.
This matters because pharmacy has become too large, too volatile, and too strategically important to manage as a black box.
The old model was built around trust in intermediaries. Employers delegated the complexity to PBMs, carriers, consultants, and point solutions, hoping the system was optimized on their behalf. In many cases, that trust was not entirely misplaced. PBMs do play an important role in administering pharmacy benefits at scale. But as pharmacy costs have continued to rise, especially in specialty and high-cost brand categories, employers have become less satisfied with high-level assurances and more interested in direct visibility.
That shift is overdue.
Transparency should not be controversial. If employers are funding the benefit, they should be able to understand the economics behind it. They should know whether formulary decisions are driven by lowest net cost, rebate optimization, clinical appropriateness, channel control, or some combination of all three. They should know where spread pricing, retained fees, referral compensation, or affiliated entities may be influencing outcomes. And they should be able to tell the difference between reported savings and real savings.
Here’s the nuance: transparency, by itself, is not a savings strategy.
Seeing the numbers is not the same thing as changing them.
That is where many employers may find the next stage of the pharmacy conversation more complicated than expected. Even with better disclosure, the hardest questions remain operational. Once you identify the cost drivers, what do you do next? If a handful of specialty claims are driving disproportionate spend, how are those cases being managed? If lower-cost pathways exist, who is responsible for identifying them, validating clinical fit, engaging the member, coordinating with the prescriber, and making sure the process is actually usable in real life?
This is where the market is heading: beyond transparency.
The most effective employers in the next few years will be the ones that treat transparency as a starting point for action. They will ask better questions about high-cost claim concentration. They will look more closely at specialty workflow, prior authorization discipline, biosimilar adoption, patient assistance opportunities, and alternative fulfillment pathways. They will pay more attention to whether their vendors are producing measurable net savings or simply offering cleaner reporting on an unchanged cost structure.
They will also become more disciplined about governance.
One of the reasons pharmacy has remained difficult to manage is that cost, compliance, member experience, and internal politics often collide. A strategy may look compelling on paper but fall apart if it creates friction with a PBM, confusion for members, or concern from legal, finance, or stop-loss stakeholders. The employers who navigate this well will be the ones that pair financial rigor with operational realism. They will seek solutions that are not only cost-conscious, but explainable, supportable, and sustainable.
That’s especially important as pharmacy continues to evolve faster than most benefit structures.
GLP-1s are changing the economics of obesity coverage. Cell and gene therapies are reshaping catastrophic claim risk. Biosimilars may create meaningful opportunity, but only if plans can turn availability into adoption. And specialty medications continue to account for an outsize share of pharmacy spend despite representing a small fraction of utilization. In that environment, employers cannot afford to rely on generic answers or summary-level reporting. They need a clearer view into what is happening and a more deliberate strategy for what to do about it.
So yes, 2026 may indeed be the year of pharmacy transparency.
But the more important shift is what comes after: employers acting like informed buyers instead of passive recipients of complexity.
That will mean asking harder questions. Expecting cleaner answers. And focusing less on theoretical savings and more on what actually changes net plan spend.
If that resonates, we’re spending a lot of time at Rescrybe thinking about how self-funded employers can bring more clarity, discipline, and measurable action to high-cost pharmacy spend. The need for transparency is real, but so is the need for practical models that help employers do something useful with it.
